MANN PACKING CO. - Executive Summary |
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EXECUTIVE SUMMARY 1. PREVENTION AND RESPONSE Mann Packing Co. operates a processing, shipping and cooling facility in Salinas, CA. Risk prevention and emergency response procedures are in place at this facility. The Emergency Response Plan lists the responsible personnel and the policies for responding to an accident involving the regulated substance. There are both portable and fixed refrigeration systems onsite and all have safeties to detect unsafe operating conditions. The fixed system supports cold storage, ice making water chilling and hydrocooling. There is an ammonia detector in the mechanical room for alarming. The portable systems have no detection since the units are outdoors. Operators are present to monitor these units when they are running. There is a list of responders experienced with ammonia refrigeration that would respond and determine specific responses for any incident. Safeties and detection equipment are tested and maintained by experienced maintenance personnel as spelled out in the SOPs and the maintenance program. 2. STATIONARY SOURCE AND SUBSTANCE DESCRIPTION Ammonia refrigeration systems are used for cold storage, water chilling, produce precooling and ice generation. A fixed system is attached to the main storage and processing building and is used for cold storage, water chilling, ice generation, and hydrocooling. There is a refrigerated dock and holding room remote from the main facility that is supported by portable trailer mounted refrigeration units. These portable units also support two vacuum cooling tubes. The fixed refrigeration system was started in 1980 and is designed as per current applicable building and safety codes. The remote dock was started in 1994 and the holding room was added to the dock in 1995. These rooms are also up to current codes and standards. Portable units vary in age. The total charge for the all the refrigeration systems is 31,500 LBS. 3. RELEASE SCENARIOS Both a worse case and an alternate release scenario were modeled for this RMP utilizing a computer modeling program. The worse case was an release of 15,000 LBS. This is the maximum amount in the largest vessel of the largest system. Release duration was 10 minutes with ambient conditions as required by EPA regulations. The alternate was a release for 17 minutes averaging approximately 105 LBS/minute. This is a more probable release due to items such as rotating seals, pressure relief valves, leaks in piping, charging system or draining oil. The modeling software used was "A Real Locations Of Hazardous Atmospheres" (ALOHA) from the National Safety Council in cooperation with the EPA. Both scenarios were considered releases in a rural setting. Release plumes were plotted on maps showing the area effected by the release. The mapping software utilized was "Mapping Application for Response and Planning of Local Operational Tasks" (MARPLOT) also from the National Security Council. Effected populations wer e estimated using "Land View III", a computer census modeling program from the Bureau of Census that is able to estimate census data of areas defined on MARPLOT generated maps. Offsite consequences were analyzed at 200 PPM level of concern for the two above release scenarios. Results show the worse case release having a potential endpoint of 2.1 miles. If the area was encircled with the 2.1 mile endpoint distance as the radius, the total area population would be approximately 17,000. This area contains schools, hospitals, parks and day care centers. The alternate scenario has considerably less offsite consequence with an endpoint of 1,557 feet at 200 PPM. A nearby industrial/commercial area would be effected. There are various measures in place or recommended as risk reduction in the Process Hazard Analysis (PHA) to limit the endpoint distances of a release. One is an ammonia monitoring system for early detection. There is an emergency control box at the main cold storage sys tem for manual pressure release. Relief valves of the portable systems supporting the vacuum cooling and remote cold storage are tied into an ammonia diffuser water tank. Preventive maintenance and safety inspections are used to insure equipment and piping is maintained and operating in a safe manner. 4. GENERAL RELEASE PREVENTION PROGRAM Mann mains a release prevention program to eliminate or minimize releases. The program includes regular inspections, monitoring equipment and logging conditions, scheduled maintenance, and operator training. Releases are documented and analyzed for ways to prevent a similar future release. A Risk Management Program which includes accident prevention procedures for the ammonia refrigeration system is maintained on-site along with this RMP. The ammonia refrigeration system has specific safety procedures to prevent a release. Operators and mechanics are trained for safe operation and maintenance of the refrigeration system. They are also train ed in emergency response procedures in the event of an ammonia release. There are emergency shut off switches outside the mechanical room for shutting down the system. An alarm and detection system monitors the facility for unsafe ammonia concentration levels and for operating conditions outside of safety set points. An emergency control box and diffuser at the main facility allows system pressure to be relieved manually. All relief valves at the remote dock and holding room prevents are tied into an ammonia diffuser tank to prevent releases to ambient. 5. FIVE YEAR ACCIDENT HISTORY There have been no reportable accidents at this facility. 6. EMERGENCY RESPONSE PROGRAM In event of a release, certain personnel are designated to determine the potential hazard and coordinate response procedures. The emergency coordinator is responsible for contacting emergency response agencies, schools, daycare centers, and acute care facilities that may be effected by the release. The coordina tor will also be responsible for evacuation of employees if necessary, and for coordination with community emergency responders if off-site evacuations are required. A copy of the Emergency Response Program is included in the Risk Management Program maintained at the facility. 7 PLANNED CHANGES TO IMPROVE SAFETY Specific recommendations resulting from the PHA are listed in the Risk Management Program. These are all minor corrections as both the fixed and portable equipment are well maintained and in safe condition. A more intensive and formalized safety training program will also be implemented. |